On February 9, 2010 AGA submitted comments to express concerns with the Energy Conservation Standards for Residential Water Heaters, Direct Heating Equipment, and Pool Heaters Proposed Rule. AGA states that DOE failed to implement the recommendations of the National Academy of Science s study authorized by the Energy Policy Act of 2005 covering appliance standards and the use of either full-fuel-cycle or extended site energy metrics. AGA's comments urge DOE to modify the basis of its rulemaking, its minimum efficiency proposal for natural gas water heaters, and its approach to looking at achieving the goals of energy efficiency and associated carbon emissions reduction.